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Privacy Policy

Last updated: 6th October 2026

This Privacy Policy explains how Gusto AI L.L.C-FZ, Dubai, United Arab Emirates (“Gusto AI”, “we”, “us”) collects, uses and protects personal data of users (“Users”, “you”) of the Gusto AI mobile application and related services (the “App”).

This policy is governed by the laws of the United Arab Emirates, in particular the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

1. Who We Are (Data Controller)

Controller: Gusto AI L.L.C-FZ, Dubai, United Arab Emirates.

Email: privacy@gusto-ai.com

Gusto AI acts as the Data Controller for personal data processed through the App.

2. Scope

This Privacy Policy applies to:

  • Users of the Gusto AI App
  • Users browsing, registering or interacting with recommendations, orders or reservations

It does not apply to restaurant partner portals or third-party platforms.

3. Personal Data We Collect

We may collect the following categories of data:

A. Account & Identity Data

  • Name or username (optional)
  • Email address
  • Login credentials or authentication tokens

B. Usage & Preference Data

  • Food preferences and taste profiles
  • Ratings, reviews and interactions
  • Search and browsing behaviour

C. Transaction & Booking Data

  • Orders and reservations made via the App
  • Selected restaurants or dishes
  • Reservation times and confirmations

D. Location Data

  • Approximate location (city/area level)
  • Only used to show relevant restaurants or availability
  • No continuous background tracking

E. Technical Data

  • Device type, Operating system, App version
  • IP address, Log and crash data

F. Health & Wellness Data (only if you connect a wearable)

If you connect a third-party wearable account (currently WHOOP or Oura), we receive, for your account only:

  • Sleep duration and sleep quality indicators
  • Recovery or readiness indicators, heart rate variability, resting heart rate
  • Daily strain, activity level and energy expenditure
  • The account identifier used by your wearable provider, and the access credentials required to retrieve the above

We treat this as sensitive personal data. We receive it only after you have explicitly connected the account and only for the categories you approved on your provider’s consent screen. You can disconnect at any time in the App; we then stop receiving data and delete what we hold (Section 8).

We do not receive your location, messages, contacts, payment data or medical records from your wearable provider.

We do not collect medical records, diagnoses or genetic data. We do collect health and wellness data from connected wearable devices, but only if you choose to connect such a device — see Section 3.F.

4. Purposes of Processing

We process personal data to:

  • Provide and operate the App
  • Deliver personalised food and dish recommendations
  • Enable orders and table reservations
  • Improve product performance and user experience
  • Provide customer support
  • Ensure platform security and prevent fraud
  • Comply with legal obligations
  • Adjust meal and recipe recommendations to your recent sleep, recovery and activity, where you have connected a wearable

Some recommendations, and the explanations shown with them, are generated with the assistance of a third-party AI service. This never includes health data (see Section 3.F).

Health data is used only for adjusting recommendations as described above. We convert the values we receive into coarse bands — for example sleep “short / normal / long”, recovery “low / medium / high” — and base recommendations on those bands using our own rule-based logic.

We do not send health data to any third-party artificial intelligence or large language model provider, and we do not use health data to train, fine-tune, evaluate or benchmark any AI model.

No medical advice. Gusto AI is not a medical device. Recommendations are meal suggestions, not medical, dietary-therapeutic or other professional advice. They are not suitable for diagnosing, treating or preventing any condition. Consult a qualified professional for medical questions.

5. Legal Basis for Processing

Under UAE PDPL, we rely on:

  • User consent (e.g. account creation, preferences)
  • Contractual necessity (e.g. processing orders or reservations)
  • Legitimate interests (analytics, security, service improvement)

Where required, consent can be withdrawn at any time.

Health data. We process health data from connected wearables solely on the basis of your separate, explicit consent, given when you connect the device. This consent is independent of your account registration and of your acceptance of our Terms. You may withdraw it at any time by disconnecting the device in the App, without affecting your use of the rest of the App.

6. Data Sharing

We may share data with:

  • Restaurant partners (only what is required to fulfil orders or reservations)
  • Delivery or logistics partners (where applicable)
  • Payment service providers
  • Cloud hosting, analytics and technology providers
  • AI service providers (currently Google) — for non-health data only. We send your taste scores, cuisine preferences and candidate dish data in order to select daily recommendations and to generate the explanations shown with them. We do not send your name, email address, precise location, or any health data from connected wearables.
  • Authorities or regulators where legally required

We do not sell user data. All third parties are contractually required to protect personal data.

Health data from connected wearables is never shared with restaurant partners, delivery partners, payment providers, advertising networks or AI providers. It is never sold or licensed. It is processed only by Gusto AI and by our cloud hosting provider for the purpose of operating the App.

7. International Data Transfers

Personal data may be processed outside the UAE (e.g. cloud infrastructure). We ensure transfers comply with UAE PDPL requirements and appropriate safeguards are in place.

8. Data Retention

We retain personal data as long as your account is active, as necessary to provide services, or as required by law. Data is deleted or anonymised when no longer required.

Health data. If you disconnect a wearable, we delete the stored access credentials immediately and the derived health data within 72 hours. If you request deletion of your health data, we delete it within 72 hours and retain no copies. Deleting your Gusto AI account deletes all health data with it.

9. User Rights

In accordance with UAE PDPL, you may request to:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion (where legally permissible)
  • Withdraw consent
  • Disconnect a connected wearable and have the data derived from it deleted, at any time and without giving a reason

Requests can be made via privacy@gusto-ai.com.

10. Security Measures

We implement appropriate safeguards, including encryption of sensitive data, secure authentication, access controls, monitoring and incident response procedures.

Access credentials for connected wearables are encrypted at rest with AES-256-GCM, and health data is stored separately from your account and order data.

11. Cookies & Tracking

The App may use essential cookies/SDKs and analytics tools. You can control permissions through your device or App settings.

12. Children’s Data

The App is not intended for users under the age of 18. We do not knowingly collect data from minors.

13. Third-Party Data Sources

Where you connect a wearable, the data originates from your account with that provider, and their own privacy policy governs how they process it:

  • WHOOP — WHOOP, Inc.
  • Oura — Oura Health Oy

Connecting or disconnecting your Gusto AI account does not change your relationship with these providers. Revoking access in your provider’s own account settings also stops data reaching us.

14. Contact

For privacy-related questions or requests: privacy@gusto-ai.com

© 2026 Gusto AI. Legal Entity: Gusto AI L.L.C-FZ, Dubai, U.A.E.